Packaging Delegated Act Tracker: ESPR Packaging DPP Status
EXPECTED 2026-2027The packaging delegated act will establish Digital Product Passport requirements for packaging placed on the EU market. This tracker covers the current status and what packaging manufacturers need to prepare.
Current Status and Timeline
| Milestone | Expected Date | Status |
|---|---|---|
| ESPR Working Plan identifies Packaging as priority | 2022–2024 | Complete |
| Preparatory study published | 2024–2025 | In Progress |
| Stakeholder consultation | 2026-2027 | Expected |
| Delegated act adopted | 2026-2027 | Expected |
| Packaging DPP mandatory | 2028-2029 | Expected |
Key Facts for Packaging Manufacturers
Packaging DPPs are expected to interact with the EU Packaging and Packaging Waste Regulation (PPWR), which is being revised in parallel with ESPR. Packaging DPPs are expected to contain: material composition, recycled content percentage, recyclability assessment (recyclability at scale in the EU), presence of substances of concern, and end-of-life sorting instructions. The PPWR sets minimum recycled content requirements for plastic packaging that will be reflected in packaging DPP data fields.
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Register Your Digital Product Passport →ESPR and the Packaging and Packaging Waste Regulation
Packaging is subject to both ESPR and the revised Packaging and Packaging Waste Regulation (PPWR), which was adopted in 2024. The PPWR sets requirements for the recyclability, recycled content, and reusability of packaging. ESPR adds requirements for DPP data disclosure for packaging products. The interaction between ESPR and the PPWR is still being worked out by the Commission, but the general principle is that the PPWR sets the framework for packaging sustainability requirements, while ESPR provides the DPP mechanism for disclosing compliance with those requirements.
The ESPR delegated act for packaging is expected to require manufacturers to disclose the following data in the DPP: the material composition of the packaging (percentage of each material type); the percentage of recycled content; the recyclability class of the packaging (under the PPWR recyclability assessment methodology); information on substances of concern in the packaging; and end-of-life instructions for consumers. This data will enable consumers to make informed choices about the packaging of the products they purchase and will provide recyclers with the information they need to process end-of-life packaging efficiently.
Frequently Asked Questions
The ESPR delegated act for packaging is expected to be adopted in 2025–2028. The exact timeline will depend on the outcome of the preparatory study and the interaction with the revised PPWR. Packaging manufacturers should plan for compliance by 2027–2030.
The PPWR sets mandatory requirements for the recyclability, recycled content, and reusability of packaging. ESPR adds requirements for DPP data disclosure. The Commission is working to align the DPP requirements under ESPR and the PPWR to avoid duplication. Manufacturers should comply with both regulations.
Single-use plastic packaging is subject to the Single-Use Plastics Directive (EU 2019/904), which restricts or bans certain single-use plastic products. ESPR adds requirements for DPP data disclosure for packaging products, including single-use plastic packaging that is not banned. Manufacturers should comply with both the Single-Use Plastics Directive and ESPR.
The PPWR sets minimum recycled content requirements for plastic packaging (30% for contact-sensitive plastic packaging by 2030, 65% for non-contact plastic packaging by 2040). ESPR delegated acts for packaging may require disclosure of recycled content data in DPPs and may set additional requirements beyond those in the PPWR.
The ESPR DPP for a product typically includes information about the product's packaging as part of the product data. The packaging DPP (if required) would be a separate DPP for the packaging itself. The Commission is working on the technical architecture for how product DPPs and packaging DPPs will interact.
Packaging and Packaging Waste Regulation: Current Status
The Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) entered into force in 2025, replacing the Packaging and Packaging Waste Directive (94/62/EC). The PPWR introduces mandatory recycled content requirements, recyclability requirements, and DPP requirements for packaging. The PPWR is the primary legislative instrument for packaging sustainability in the EU, and the ESPR delegated act for packaging will complement it by setting ecodesign requirements for packaging as a product category. The PPWR and ESPR delegated act for packaging are being developed in coordination to avoid duplication and ensure a coherent regulatory framework for packaging sustainability.
PPWR Recycled Content Targets and ESPR Packaging DPP
The PPWR sets mandatory minimum recycled content requirements for plastic packaging: 30% recycled content for PET bottles from 2030, 10% recycled content for other plastic packaging from 2030, and 35% recycled content for PET bottles from 2040. These targets will be verified through the ESPR packaging DPP — the DPP will contain the recycled content percentage and the verification methodology used to determine it. The verification methodology must comply with the EU Commission's implementing act on recycled content calculation and verification, which is currently under development. Manufacturers that use recycled plastic content in their packaging should begin documenting their recycled content data now, as the verification requirements are expected to be rigorous.
Packaging DPP and Extended Producer Responsibility
Extended producer responsibility (EPR) schemes for packaging are already operational in all EU member states. The PPWR harmonises EPR requirements across the EU and introduces modulated EPR fees based on the recyclability and recycled content of the packaging. The ESPR packaging DPP will provide the data needed for EPR fee modulation — the DPP will contain the recyclability assessment result (recyclable at scale / recyclable but not at scale / not recyclable), the recycled content percentage, and the carbon footprint per packaging unit. EPR scheme operators in each member state will use this data to calculate the correct EPR fee for each packaging type. Brand owners should ensure their packaging DPP data is accurate and up to date, as EPR fees are calculated based on the declared DPP data.
Packaging and Packaging Waste Regulation (PPWR) and ESPR
The Packaging and Packaging Waste Regulation (PPWR, EU 2025/40) is a separate regulation from ESPR but shares the same policy objectives — reducing the environmental impact of packaging and increasing packaging recyclability and recycled content. The PPWR introduces DPP-like requirements for packaging — specifically, the requirement for a QR code on packaging that provides information on the packaging material composition, recyclability, and recycling instructions. The PPWR QR code requirements are aligned with the ESPR DPP technical requirements (GS1 Digital Link, JSON-LD data format), which means that manufacturers implementing ESPR DPP systems can use the same infrastructure for PPWR packaging compliance. The PPWR entered into force in February 2025, with a transition period for most requirements until 2030.
Packaging DPP: What Data Must Be Disclosed
The PPWR and the ESPR packaging delegated act (expected 2025) will require packaging to have a DPP containing: packaging material composition (primary material, percentage by weight), recyclability class (A–E, based on the recyclability assessment methodology in the PPWR), recycled content percentage, deposit scheme information (if applicable), and end-of-life sorting instructions (which recycling stream the packaging should be placed in). The packaging DPP must be accessible via a QR code on the packaging. For small packaging items where a QR code cannot be applied directly, the QR code can be applied to the outer packaging or provided in the product documentation.
Packaging Delegated Act: Expected Timeline and Scope
The ESPR packaging delegated act is expected to be published in 2025, building on the PPWR framework. The delegated act will specify the minimum recycled content requirements for different packaging types (plastic, paper, glass, metal), the recyclability assessment methodology, and the DPP data format for packaging. Packaging manufacturers and brand owners (who are responsible for the packaging DPP under the PPWR extended producer responsibility framework) should begin preparing for compliance now by assessing their current packaging portfolio against the expected PPWR and ESPR requirements and identifying packaging designs that will need to be modified to meet the recyclability and recycled content requirements.
Packaging DPP: Implementation Timeline for Brand Owners
Under the Packaging and Packaging Waste Regulation (PPWR, EU 2025/40), brand owners (the companies whose brand appears on the packaging) are responsible for the packaging DPP, not the packaging manufacturers. This is different from the ESPR product DPP, where the product manufacturer is responsible. Brand owners must ensure that all their packaging has a functioning DPP before the PPWR compliance deadline. For large brand owners with thousands of SKUs, implementing DPPs for all packaging is a significant project — it requires collecting material composition data from all packaging suppliers, implementing a DPP platform, generating QR codes for all packaging designs, and updating all packaging artwork. Brand owners should begin this project now, as the PPWR compliance deadline for most packaging types is 2030, but the data collection and platform implementation work will take 2–3 years.
PPWR Packaging DPP: Implementation Priorities for Brand Owners
Brand owners with large product portfolios face the most complex packaging DPP implementation challenge — they must implement DPPs for hundreds or thousands of packaging designs, each with different material compositions, suppliers, and recycled content levels. The most effective approach for large brand owners is to implement a centralised packaging data management system that collects material composition data from all packaging suppliers and generates DPP data automatically. This system should be integrated with the brand owner's existing packaging artwork management system so that QR codes are automatically added to all new packaging designs and existing packaging designs are updated at the next print run. Brand owners should also implement a supplier data collection programme — requiring all packaging suppliers to provide material composition data in a standardised format that can be imported directly into the packaging data management system. This programme should be launched now, as collecting data from hundreds of suppliers takes 12–18 months.
The PPWR introduces a new concept of "packaging design for recyclability" — packaging must be designed to be recyclable in the waste management systems that are available in the EU member states. The EU Commission will publish harmonised criteria for packaging recyclability by 2027, and packaging that does not meet these criteria will be prohibited from being placed on the EU market from 2030. Brand owners should begin assessing the recyclability of their packaging portfolio against the expected harmonised criteria now — packaging that does not meet the criteria will need to be redesigned before 2030. The redesign process for complex packaging formats (multi-material packaging, packaging with functional barriers) can take 2–3 years, so brand owners that begin their recyclability assessment now will have sufficient time to complete the redesign before the 2030 deadline.